Dawn M. K. v. Commissioner of Social Security

Summary

The document is a report and recommendation in a Social Security disability appeal in the U.S. District Court for the Western District of Virginia. The magistrate judge concludes that the ALJ improperly evaluated the claimant’s fibromyalgia symptoms under SSR 16-3p and Arakas v. Commissioner, including by relying on objective medical evidence and failing to distinguish fibromyalgia-related analysis from other impairments. The report recommends reversing the Commissioner’s decision and remanding the case under the fourth sentence of 42 U.S.C. § 405(g).

Holdings

1. An ALJ may not rely on objective medical evidence, even as one of multiple factors, to discount a claimant's subjective statements concerning the intensity, persistence, or limiting effects of fibromyalgia symptoms.
2. An ALJ must sufficiently separate the analysis of fibromyalgia from the analysis of other impairments when discussing objective medical evidence, so that the court can determine whether impermissible objective-evidence reasoning affected the fibromyalgia evaluation.

Questions Presented

1. Whether the ALJ properly evaluated Dawn's fibromyalgia-related symptoms under SSR 16-3p and Arakas v. Commissioner of Social Security.
2. Whether the ALJ improperly relied on objective medical evidence to discount subjective complaints concerning fibromyalgia.
3. Whether the ALJ adequately separated the analysis of fibromyalgia from the analysis of the claimant's other impairments so that meaningful judicial review was possible.

Disposition

reversed_and_remanded